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Fundamental Issues In U.S. Taxation of Foreign Entertainers and Athletes

By Robert M. Jason
June 01, 2016

This article is Part One of a two-part article. Part Two will appear in our July 2016 issue.

The United States taxes its citizens and resident aliens on their worldwide income; nonresident aliens are taxed on their U.S. source income and income that is effectively connected with a trade or business in the U.S. These seemingly simple terms ' “citizen,” “resident,” “nonresident,” “U.S. source,” “effectively connected with a trade or business in the U.S.” (well, this last term doesn't seem so simple) ' have spawned volumes of regulations, rulings, cases and articles, the essence of all of which is to determine who is subject to tax in the U.S., and on what.

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